This article focuses on a specific component of the US Department of Housing and Urban Development’s (HUD’s) strategy to implement fair housing policy, its requirement for local jurisdictions that receive community development block grant (CDBG) dollars to prepare an analysis of impediments to fair housing choice (AI) report. The article’s analysis is based on an evaluation of the City of Buffalo’s 2004 AI report. The evaluation was conducted by a local fair housing organization in collaboration with university-based researchers. The findings from the evaluation revealed that the City had made little progress in implementing the action plan from its AI report over an eight year period. This was an outgrowth of local funding constraints, limited staff capacity, ambiguous HUD rules for AI reporting, and a lack of political will to pursue fair housing in Buffalo. In light of these findings, we recommend that HUD: mandate timeframes for AI implementation, require AI updates at regular intervals, and more clearly specify the format and content of AI reports. We also recommend that HUD require jurisdictions to include evaluation plans in their AI reports and measure outcomes from the implementation of AI action plans. These reforms will enhance the ability of AI reports to serve as effective planning tools for the affirmative furthering of fair housing policy.

National Commission on Fair Housing and Equal Opportunity (2008). The future of fair housing: Report of the national commission on fair housing and equal opportunity. Washington DC: National Commission on Fair Housing and Equal Opportunity.

US Department of Housing and Urban Development (2004). Memorandum of September 2: Analysis of impediments to fair housing choice reissuance. Washington DC: US Department of Housing and Urban Development.

US Department of Housing and Urban Development (2007). Memorandum of February 9: Affirmatively furthering fair housing in the community development block grant program. Washington DC: US Department of Housing and Urban Development.

US Government Accountability Office (2010). Housing and community grants: HUD needs to enhance its requirements and oversight of jurisdictions’ fair housing plans. Washington DC: US Government Accountability Office.